DCT

1:25-cv-13604

SharkNinja Operating LLC v. Guangxi Haochen Information Technology Co Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-13604, D. Mass., 11/26/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Massachusetts because Defendant conducts business in the district, including selling, offering for sale, and shipping the Accused Product into the district.
  • Core Dispute: Plaintiff alleges that Defendant’s replacement cleaning heads for "vac-mops" infringe a patent related to a disposable cleaning head with an integrated dirt collection chamber.
  • Technical Context: The technology relates to hybrid floor cleaning appliances, or "vac-mops," which combine vacuuming and mopping functions to handle both wet and dry debris, a significant segment of the household appliance market.
  • Key Procedural History: The complaint alleges that Plaintiff notified Defendant of its infringement of the patent-in-suit via the Amazon APEX program prior to filing the lawsuit, which may form the basis for its willfulness allegations.

Case Timeline

Date Event
2017-09-11 U.S. Patent No. 10,993,594 Earliest Priority Date
2021-05-04 U.S. Patent No. 10,993,594 Issued by USPTO
2025-11-26 Complaint for Patent Infringement Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,993,594 - "Cleaning Device"

The Invention Explained

  • Problem Addressed: The patent describes the challenge of cleaning surfaces with both wet and dry debris, which often requires using multiple separate devices (e.g., a vacuum then a mop). This process can be time-consuming, messy, and require significant after-use maintenance of the cleaning appliances (’594 Patent, col. 4:1-31).
  • The Patented Solution: The invention is a disposable, removable cleaning head for a vacuum appliance that integrates a dirt collection chamber directly onto the head. This design allows a user to suction both wet and dry debris into the chamber and then dispose of the entire head unit without needing to empty a dirty container or touch the collected waste, offering a more hygienic and convenient cleaning process (’594 Patent, col. 4:32-42; FIG. 2). The chamber is permanently attached to the head, and the entire assembly is intended for disposal after use (’594 Patent, col. 4:55-58).
  • Technical Importance: This approach combines the functions of vacuuming and mopping into a single, disposable component, aiming to reduce cleaning time, simplify appliance maintenance, and improve sanitation for the user.

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 and alleges infringement of "one or more claims" of the patent (Compl. ¶19).
  • The essential elements of independent claim 1 include:
    • A replacement head for a cleaning device.
    • A planar cleaning sheet with a lower surface for contacting the floor.
    • A housing that defines a chamber for receiving debris.
    • The housing is positioned only on a front half of the planar cleaning sheet.
    • A trailing edge of the cleaning sheet extends rearward from a rear edge of the housing.
    • The housing includes an opening for debris to flow into the chamber.
    • The trailing edge is defined by a portion of the cleaning sheet's outer perimeter.

III. The Accused Instrumentality

Product Identification

The accused product is a replacement cleaning head identified by Amazon.com ASIN B0FHVTXJTS (the "Accused Product") (Compl. ¶5).

Functionality and Market Context

The complaint alleges the Accused Product is a "replacement cleaning head for a vac-mop including a dirt collection chamber attached to the cleaning head" (Compl. ¶4). The functionality described in the complaint mirrors the elements of the asserted patent claim, alleging the product is a disposable head comprising a cleaning sheet and a forward-positioned housing for collecting debris (Compl. ¶21). The complaint suggests the product directly competes with Plaintiff's products (Compl. ¶6).
No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint provides a narrative infringement theory by reciting the elements of claim 1 and alleging that the Accused Product possesses each corresponding feature (Compl. ¶21).

’594 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a planar cleaning sheet having a lower surface configured to contact a surface to be cleaned The Accused Product comprises a planar cleaning sheet with a lower surface configured to contact a surface. ¶21 col. 5:61-63
a housing defining a chamber therein for receiving debris The Accused Product comprises a housing that defines a chamber for receiving debris. ¶21 col. 5:21-23
the housing positioned only on a front half of the planar cleaning sheet and extending adjacent a leading portion of the cleaning sheet The housing in the Accused Product is positioned only on a front half of the planar cleaning sheet and extends adjacent a leading portion of the cleaning sheet. ¶21 col. 7:42-43; FIG. 4
such that a trailing edge of the planar cleaning sheet is configured to extend rearward along the surface to be cleaned from a rear edge of the housing A trailing edge of the planar cleaning sheet is configured to extend rearward from a rear edge of the housing. ¶21 FIG. 4
the housing including an opening formed therein for allowing debris to flow into the chamber The housing includes an opening that allows debris to flow into the chamber. ¶21 col. 7:22-28
wherein the trailing edge is defined by a portion of the outer perimeter edge of the cleaning sheet The trailing edge of the Accused Product is defined by a portion of the outer perimeter edge of the cleaning sheet. ¶21 FIG. 2

Identified Points of Contention

  • Scope Questions: A central dispute may revolve around the specific geometric and positional limitations of the claim. The case raises the question of whether the Accused Product’s housing is, in fact, "positioned only on a front half of the planar cleaning sheet" as strictly required by the claim language.
  • Technical Questions: A key factual question will be whether the physical structure of the Accused Product meets the claim's requirement that the "trailing edge of the planar cleaning sheet is configured to extend rearward... from a rear edge of the housing." This requires a specific spatial relationship between the two components that will need to be proven with evidence of the product's construction.

V. Key Claim Terms for Construction

  • The Term: "positioned only on a front half of the planar cleaning sheet"
  • Context and Importance: This term is critical because it defines the core structural layout of the claimed invention. The infringement analysis will depend heavily on whether the Accused Product's debris housing is confined to the front 50% of the cleaning sheet. Practitioners may focus on this term because the word "only" acts as a significant constraint on the claim's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification does not provide a textual definition of "front half." A party might argue that the term should be interpreted functionally, based on the drawings, to mean the portion of the head that leads during forward cleaning motion, without requiring a precise geometric bisection.
    • Evidence for a Narrower Interpretation: The plain meaning of "only on a front half" suggests a strict geometric limitation. The patent's figures, such as FIG. 2 and FIG. 4, consistently depict embodiments where the dirt collection chamber (112) occupies the leading portion of the cleaning head (114), with the remainder of the sheet extending rearward, which could be cited to support a narrow, structurally defined interpretation.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Defendant encourages retailers to sell and consumers to use the Accused Product (Compl. ¶19), including by "knowingly instructing" customers on its use (Compl. ¶24). Contributory infringement is alleged on the basis that the Accused Product is a material part of the patented invention, is not a staple article of commerce, and is known by Defendant to be especially adapted for an infringing use (Compl. ¶23).
  • Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged pre-suit knowledge. This knowledge is asserted to arise from a notification Plaintiff sent to Defendant "through the Amazon APEX program, Complaint ID: 18722318981" (Compl. ¶22).

VII. Analyst’s Conclusion: Key Questions for the Case

The resolution of this dispute may depend on the court's findings regarding the following key questions:

  • A core issue will be one of structural correspondence: Does the physical construction of the Accused Product satisfy the specific geometric limitations of claim 1? In particular, the dispute may center on whether the product’s debris housing is "positioned only on a front half" of its cleaning sheet and whether its "trailing edge" extends rearward from the housing in the manner claimed.
  • A related question will be one of claim construction: How will the court define the scope of "positioned only on a front half"? The interpretation of this precise spatial language—whether it requires a strict geometric boundary or allows for a more functional interpretation based on the patent's figures—could be dispositive for the infringement analysis.
  • An evidentiary question regarding damages will be one of pre-suit knowledge: Will the notice allegedly provided through the "Amazon APEX program" be sufficient to establish that Defendant had actual knowledge of the ’594 Patent and its alleged infringement, thereby supporting the claim for willfulness?